NARESHKUMAR PUNJIRAM PATEL,AHMEDABAD vs. DCIT, CIRCLE 3(1)(1), AHMEDABAD (OLD) DCIT, CIRCLE-7(2), AHMEDABAD, AHMEDABAD

ITA 1588/AHD/2026Status: DisposedITAT Ahmedabad11 September 2026AY 2011-125 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A)'s order did not specifically address the assessee's submissions and legal contentions. Therefore, the Tribunal set aside the additions and restored the issues to the Assessing Officer for de novo adjudication, directing both parties to cooperate.

What were the facts?

The assessee's appeal against the CIT(A)'s order dismissing their appeal was heard. The CIT(A) had upheld an ex-parte assessment order passed under Section 144 r.w.s 147, which included disallowances for excessive interest and under Section 14A.

What were the issues?

Whether the CIT(A) erred in dismissing the appeal without affording sufficient opportunity of being heard and properly considering the assessee's submissions. The merits of the disallowances were also challenged.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, C” BENCH, AHMEDABAD

Per Rahul Chaudhary, Judicial Member:

1.

The present appeal has been preferred by the Assessee against the Order, dated 25/02/2026, passed by the Ld. Commissioner Of Income Tax, Appeal- ADDL/JCIT(A)-1, Chandigarh [hereinafter referred to as the ‘CIT(A)’] whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 23/10/2018, passed under Section 144 r.w.s 147 of the Income Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment Year 2011-2012. 2. The Assessee has raised following grounds of appeal:

1.

The order passed by the

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →